He contends that non-SEC filers do not have to comply with Industry Guide 7.
To be specific, I said "I'm not sure that Industry Guide 7 requirements apply to them as a non-filer"...and that I'm willing to be corrected. Not quite the same as "contending", but I'm guilty of being a stickler for semantics.
That is incorrect. All ISSUERS must comply with Industry Guide 7, not just SEC REGISTRANTS.
"Industry Guide 7 The specific disclosure requirements of Industry Guide 7 under the Securities Act and Exchange Act apply to all issuers, including small business issuers, engaged in mining operations. Guide 7 is applicable to all mining companies, not just small business issuers."
The term "Issuer" means any company that issues shares to the public. That includes non-SEC registered and reporting companies. Claiming reserves without a final (bankable) feasibility study is fraudulent. Quite a few reporting and non-reporting companies have been nailed on that specific issue.